Page 67 - FDCC Deposition Drills

Deposition Drills How to Teach Deposition Skills
Who Am I?
It is important to get a witness into a rhythm and have them repeatedly answer “yes” to your cross examination questions.
EXPLANATION
Teaches participants how to solicit the answer “yes” from deponents.
EXERCISE
Have the participants read your firm bio and ask you questions about you. The goal is to ask only leading questions, one fact per question, secure “yes” answers, have each question lead from the last into the next and have the questions be short. Instead of having each participant ask only one question per turn, have each cover one topic during their turn, such as your education, training, experience, publications of leadership. Each participant will draw out their topic as much as possible while applying as many of the other cross exam rules. You’ll step in as needed and provide friendly critiques on specific questions and offer “better” questions to ask.
LESSONS LEARNED
Developing a cadence with a witness where you train them to say “yes” repeatedly is an effective cross examination technique that takes practice.
A FEW QUESTIONS TO DISCUSS
Why is having a witness agree with you important?
How can you train a witness to agree with you?
What’s the best way to phrase questions to get a witness to agree with you?
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SECTION 04 CROSS EXAMINATION